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SPP: Public Agency Procedural Compliance Self-Assessment

Corrective Action Plans

Plan must correct all errors as soon as possible and no later than one year.

Each individual instance of noncompliance must be corrected as specified in the self-assessment report, and steps must be taken to ensure future compliance. When the public agency’s procedural compliance self-assessment indicates an error, the public agency must develop agency-wide corrective actions to correct the identified noncompliance and to ensure future compliance.

All public agency noncompliance must be corrected as soon as possible and no later than one year from the date WDPI notifies the public agency of noncompliance by letter. WDPI will verify the agency has corrected each individual case of noncompliance and the agency is currently in compliance with regulatory requirements.

A public agency is required to submit to the WDPI a corrective action plan addressing the noncompliance via the web-based self-assessment report. The WDPI strongly recommends self-assessment results and proposed corrective actions be reviewed with the agency’s ad hoc self-assessment committee prior to submitting a corrective action plan to WDPI. The corrective action plan includes required activities to bring about compliance and to ensure future compliance. Examples include revising policies, procedures, or forms; training staff; increasing supervision; changing staff assignments; or adding staff and other resources. WDPI’s web-base reporting system provides the proposed correction strategies reasonably calculated to correct the identified noncompliance in a timely manner and ensure future compliance.

Each public agency needs to review its internal control system as part of participation in the Procedural Compliance Self-Assessment (PCSA). An internal control system allows a Local Educational Agency (LEA) to detect and promptly correct noncompliance. Data from an internal control system assists the LEA to determine root causes of noncompliance. Finally, an internal control system helps ensure the LEA continues to maintain compliance with federal and state special education requirements.

Some LEAs review individualized education programs (IEPs) for compliance after the IEP team meeting has occurred. LEAs must use caution when using this approach. When the person reviewing the IEP did not participate in the IEP team meeting, the person cannot know the substance of the discussion that occurred.

Corrections to IEPs may be made without a meeting provided the corrections do not affect or change a student’s educational placement and the LEA and the parent agree. The LEA must provide written notice describing the changes and a copy of the revised IEP. The LEA must reconvene the IEP team in order to make any corrections affecting or changing a student’s educational placement.

Maintain documentation within public agency.

As you complete your corrective action plans, please maintain documentation within the public agency.

For errors in individual student records, you must be able to demonstrate you corrected all identified student noncompliance as soon as possible by taking the steps identified by WDPI.

To demonstrate correct implementation of requirements, WDPI will review a reasonable sample of records created after your public agency has completed the self-assessment. The records will be reviewed for compliance with any requirement with one or more instances of identified noncompliance reported through the self-assessment.